ENVIRONMENTAL

MONITORING

PLAN

for imidacloprid

ASIAN LONGHORNED BEETLE COOPERATIVE ERADICATION PROGRAM

Boston & Worcester, Massachusetts

2012

 

United States 

Department of

Agriculture 

Animal and

Plant Health

Inspection

Service

Plant Protection

and Quarantine

Prepared by the

Environmental 

Compliance Team May 2012
2012 Environmental Monitoring Plan 1

General

The United States Department of Agriculture (USDA) - Animal and Plant Health Inspection 

Service (APHIS) Directive 5640.1 (4/19/02) commits the Agency to a policy of fulfilling the 

mandates of the National Environmental Policy Act; the Endangered Species Act; the Federal 

Insecticide, Fungicide, and Rodenticide Act; and other statutes that require monitoring the 

potential effects of Federal programs on the environment. The monitoring described in this 

Environmental Monitoring Plan (EMP) supports these commitments for the Massachusetts Asian 

Longhorned Beetle (ALB) Cooperative Eradication Program.

Environmental sampling for residues of imidacloprid is proposed to validate the assumptions of 

the Environmental Assessments created for the program and to address specific concerns raised 

by the public. Imidacloprid is a systemic insecticide used as a treatment of ALB host trees at 

risk for infestation. ALB host trees may be treated via ground or trunk injection based on the 

size of the tree, local hydrology, and other factors. Targets identified for monitoring include 

groundwater, surface water, and non-target organisms. Monitoring will be conducted to 

determine if ALB Program systemic treatments of host trees result in the movement of 

imidacloprid beyond the immediate treatment area. 

Samples collected as part of this plan will be reported to the ALB Program management in an 

annual report. If any residue samples seem unusually high, ALB Program management will be 

contacted immediately to determine what, if any, action may be needed to adjust Program 

operating procedures. This monitoring plan is a working document and will be updated as 

needed based on new information provided to the Environmental Compliance Team (ECT). It is 

designed to be a reference document for staff that will work with the Environmental Compliance 

Team to collect and document monitoring samples during the ALB eradication program. 

Human and Environmental Health

Objectives

Monitoring for potential exposure is designed to: 

1. demonstrate the effectiveness of ALB operational procedures in excluding or minimizing 

exposure of the public and the environment to Program-applied imidacloprid;

2. collect data which can be used to evaluate whether the assumptions used in the Environmental 

Assessments are valid estimates of potential exposure of the public and the environment 

to Program-applied imidacloprid; and

3. investigate any Program-related complaints or reports of adverse effects on public health, 

worker safety, environmental quality, or non-target species.

Methods

This document is a reference for ALB program staff. If additional or new types of monitoring 

are necessary, please contact Bob Baca at 301-851-2292 or by email at 

robert.m.baca@aphis.usda.gov for guidance. APHIS environmental monitoring is flexible and 

easily altered, but discussions will be needed to determine the best course of action given the 

analytical tools available.
2012 Environmental Monitoring Plan 2

Sampling Locations

It is recommended that sample locations from 2011 are used again in 2012 in areas where 

treatments are expected to occur in 2012. Pre-treatment samples should be obtained in the weeks 

prior treatment if at all possible, followed by samples through time as described below. If new 

treatment locations are added, additional sample locations should be considered in consultation 

with the ECT. In locations where treatments are not expected in 2012, it is recommended that 

half to all sample locations in 2011 are sampled in 2012 in order to track residues through time, 

especially if those areas may be treated at some point in the future. If not sampling all prior 

locations, sites should be sampled throughout the entire area as opposed to concentrating 

sampling in one or a few treatment areas.

Sensitive Site Inventory

The ALB program will identify sensitive sites prior to the initiation of chemical treatments. 

Sensitive sites are areas where the public may be exposed directly to chemicals and areas where 

there are specific concerns about potential impacts due to program activities. The program will 

identify any ground or surface waters used as a source of drinking water in or adjacent to the 

proposed treatment area. Additional sensitive sites may include, but are not limited to, the 

location of apiaries, schools and playgrounds, and vernal pools.

Descriptions and locations of sensitive sites identified by the program will be provided to the 

ECT. It is preferred that these lists be submitted in an electronic form, but they may also be 

submitted as a printed hard copy. Note the name and location of the water, the type of water 

(ground, surface, lake, etc.), and the distance and direction from the nearest treatment area. Prior 

to the start of chemical treatments, provide the list of sensitive sites to the ECT at the following 

address:

Dr. Robert Baca, USDA-APHIS-PPQ, 4700 River Road, Unit 150, Room 5A-04B,

Riverdale, MD 20737 or via email to robert.m.baca@aphis.usda.gov

Minimum Required Sample Sizes

Samples collection procedures are described below, but for easy reference, the following table 

provides the minimum sample sizes required to analyze a single sample type for imidacloprid:

It may be possible to analyze smaller samples, but at best they will be less precise. If the 

minimum sample size is not available, collect as much as possible from the sample location. The 

table above shows the types of samples that the lab can currently analyze. If other types of 

Sample Type Minimum Size

Leaves, twigs, bark 50 grams

Soil, sediment 50 grams

Sap, honey 50 ml

Water 4800 ml

Bees 25 bees
2012 Environmental Monitoring Plan 3

samples are collected, their analysis is not guaranteed and it could take several months for the lab 

to develop a satisfactory analytical method. Do not take samples beyond those in the table, as 

the lab may not have techniques to analyze such samples.

Surface Water samples

Surface water samples will be collected near the shore of ponds, lakes, or reservoirs, with 

priority given to any identified as a source of drinking water. Pre-treatment surface water 

samples should be collected approximately one week prior to the initiation of the spring 2012

programmatic chemical treatments. Additional samples should be collected at these stations

approximately one week following treatments and then approximately one, three, and six months 

later. Care should be exercised to ensure the water samples are free of turbidity and sediment. 

4.8 liters of water will be collected for analysis from each sample station. (For minimum sample 

sizes for all sample types, see the last page of this document.) Following collection, samples will 

be kept on ice, in the dark, and remain chilled until they can be frozen for shipment. For more 

detailed information on sampling procedures, refer to SOP EM-03 Collection of Water Samples.

This and other referenced SOPs are available at 

http://www.aphis.usda.gov/plant_health/plant_pest_info/emt/support_docs.shtml. 

Groundwater samples

Groundwater monitoring wells, installed as part of third-party subsurface environmental 

investigations, have been identified in the City of Worcester, and the Towns of Holden, West 

Boylston, and Shrewsbury. Groundwater samples in 2012 should mirror that done in 2011 by 

using the same sites and methods (where Program staff work with city staff in collecting the 

water samples.) If new well are identified, they also may be sampled. Once collected, water 

samples should be processed according to SOP EM-03 Collection of Water Samples. (Do not use 

SOP EM-14 Collection of Groundwater Samples, as that describes techniques for collecting 

water from wells. It is understood that city staff will actually collect the water from the well and 

provide it to Program staff.) 

Leaf Litter Samples

Whenever possible, leaf litter samples (not leaves from treated trees) will be collected each time 

ground- and surface water samples are collected. Leaf litter will be collected around treated trees 

(no conifer needles) near and up-gradient from the monitoring wells. If no leaf litter is available, 

please note that on the 2060 Environmental Monitoring Form for the groundwater sample. Do 

not collect leaves that are on trees if no leaf litter is available. For more detailed information on 

sampling procedures, refer to SOP EM-07 Collection of Vegetation Samples.

Soil Samples

Whenever possible, soil samples will be collected each time ground- and surface water samples 

are collected. Soil from within about three to six inches from the surface will be collected 

around treated trees. For more detailed information on sampling procedures, refer to SOP EM06 Collection of Soil Samples.
2012 Environmental Monitoring Plan 4

Vernal Pool-Related Samples

If vernal pools are identified for environmental monitoring, the same sampling techniques above 

for water, soil, and leaf litter are appropriate. Water should be collected from the pool directly, 

and care should be taken to not stir up the sediment (sediment makes the chemical analysis more 

difficult). Soil samples should be taken from the dry pool area at those times of year when water 

is absent. If water is present, soil samples should be taken from the wet soil adjacent to the 

vernal pool, but no so close as to mix up the soil and pool water. Leaf litter samples should also 

be taken in close proximity to the vernal pool.

Bee-Related Samples

The Agricultural Research Service (ARS) of USDA is working cooperatively with APHIS to 

investigate the response of bee hives to imidacloprid treatments in the Worcester area. The ARS 

experiment is very thorough with very sensitive analytical capabilities. Any monitoring 

conducted as part of this plan will be used to supplement the samples collected by ARS, and will 

not seek to duplicate their work. Monitoring of bees and honey is not anticipated in the Boston 

area at this time, but could easily be incorporated into the monitoring scheme as needed.

If safe and practical, the Program should work with ARS and local beekeepers to collect bee and 

honey (from the hive) samples. As sampling through time is expected, it is optimal to work with 

beekeepers who will agree to multiple sampling events each year. Preference should be given to 

beekeepers with hives in proximity to treatments, but sampling is encouraged throughout the 

Worcester area. 

Bee and honey samples should be collected from each hive. Samples should be collected prior to 

the start of spring treatments, approximately one week following treatments, one month 

following treatments, and at two-month intervals thereafter. A single sample of bees from a hive 

should comprise 25 or more bees. Healthy bees should be collected whenever practical, placed 

in a foil bag, and frozen prior to shipping (for details, see SOP EM-08 Collection of Insect

Samples). A single honey sample from a hive should be 50 ml, and need only be kept dark prior 

to shipping. Freezing the honey may break the glass sample container.

Monitoring for Incidents or Complaints

Priority sampling will be conducted to investigate incidents of unknown origin involving nontarget species or other unintended environmental or human health impacts possibly associated 

with Program-applied imidacloprid. Information about priority sampling can be found in SOP 

EM-09, Priority (Emergency) Sampling. Collect priority samples as soon as possible after the 

complaint, request, or problem is reported. Contact the ECT at 301-851-2292 to collaborate on a 

sampling plan, sampling methods, and types of samples to collect in order to optimize the 

investigation. If the incident occurs on a weekend, commence the investigation and sampling 

without delay, and contact the ECT as soon as possible on Monday.

Proper documentation of the incident, investigation, and samples is extremely important. When 

responding to priority incidents, send to the ECT all GPS maps showing the site, location where

samples were collected, the nearest treatment area, and treatment history. Be sure to completely 

fill out all information on the APHIS 2060 forms with each sample. Be sure to provide an 
2012 Environmental Monitoring Plan 5

incident/complaint report to the ECT, along with any other information that you feel will be 

helpful in resolving the incident (i.e. photos, observations at the site, etc.).

Endangered and Threatened Species

There are no federally protected species in the eradication area at this time. Should the 

eradication area expand to areas where protected species become a concern, monitoring may be 

required and this monitoring plan will be updated accordingly. 

Sample Processing

Shipment of Samples

Ship all samples, including dye cards, by using some form of overnight delivery. See SOP EM17, Packaging and Shipping of Samples for details. This applies to all samples, whether they 

are priority or routine. Do not ship samples using USPS Priority Mail or standard ground service 

with other carriers. Overnight delivery allows the sample to stay frozen or at least cold. 

Shipping any other way will take several days and can ruin the sample. As part of sampling 

supplies, you should order a shipping label for the overnight delivery of monitoring samples (see 

order form at the end of this document).

All samples must be shipped to the Agricultural Marketing Service, National Science Laboratory 

(AMS-NSL) in Gastonia, North Carolina at: 

Attention: Roger Simonds

AMS National Science Laboratory (NSL)

801 Summit Crossing Place Suite B

Gastonia, NC 28054 

Phone: 704-867-3873

This is a new analytical lab; DO NOT ship samples to Gulfport, MS as that lab is now closed.

Be sure that all samples are frozen (except for honey), shipped in a cooler box (not a regular 

cardboard box), and kept cold during shipment. To keep samples cold, ship samples on ice. Do 

not use dry ice, since it will cause the sample containers to crack or break. Either use “blue ice” 

containers (the reusable plastic containers with the blue liquid/gel inside) or contained regular ice 

(that is, seal the ice in zip-loc bags). Unsealed ice will melt and leak during shipment, causing 

unnecessary concern in transit or when received at the laboratory.

Documentation

Complete a separate APHIS 2060 form for each sample collected. Only use original 2060 forms 

supplied by the Gulfport Laboratory for documentation. Instructions for completing the APHIS 

2060 forms are on the back of each form. All appropriate sections of the form should be 

completed. Samples should be marked as “routine” unless they were collected for a complaint or 

incident investigation where they should be marked as “priority.” For each sample, submit the 

blue copy of the APHIS 2060 form to the AMS-NSL Laboratory with the sample, the white

copy of the form to the lab in the sample shipping container but separate from the sample, and 
2012 Environmental Monitoring Plan 6

the yellow copy of the form (and any maps, photos, etc.) to the ECT. Keep the pink copy of 

each form you submit as a record in your local office.

Supplies

Although APHIS staff in Mississippi will no longer be conducting chemical analyses, they will 

continue to provide monitoring supplies. A form for ordering supplies is located at the end of 

this document. The lab prefers that supply orders be faxed to them using the numbers listed on 

the checklist rather than leaving a voice message for orders. Note that certain general office 

supplies cannot be ordered by this checklist and should be obtained locally by the program.

Responsibilities

APHIS-PPQ Environmental Compliance staff in Riverdale, Maryland will:

1. Review and interpret field and pesticide residue data from the sample collectors and the 

laboratory. Contact the sample collector for clarification as soon as possible if any field 

data is incomplete or unclear. Notify the Program Director or Manager immediately if

any residue data is unexpectedly high in value.

2. Provide training, clarification, and interpretation on how to implement the Environmental 

Monitoring Plan.

3. Submit a comprehensive interpretive report to the Program Director and the National 

Coordinator within 60 working days of receiving all of the Program’s field data and

sampling results.

APHIS-PPQ Center for Plant Health Science Technology staff in Mississippi will:

1. Prepare and ship sampling containers and equipment required for collection and submission 

of environmental monitoring samples..

2. Provide instructions on methods for collecting, preserving, and shipping samples.

3. Coordinate communication between the PPQ - Environmental Compliance staff and the 

AMS-NSL to resolve sample condition and analysis issues.

4. Review and report AMS-NSL analysis results to PPQ - Environmental Compliance

APHIS-PPQ Field Personnel or Cooperators, will:

1. Ensure that sufficient resources from the Program are allocated for completing the monitoring 

activities described in the Environmental Monitoring Plan (EMP).

2. Follow instructions in the EMP and referenced SOPs to develop a plan for sample collection 

and documentation, including:

a. Collection of the type and number of samples recommended in the EMP.

b. Completion of a separate APHIS 2060 form for each sample that is collected.

c. Providing all the information necessary to document the samples. Send all supporting 

documentation, including a copy of the appropriate APHIS 2060 forms to the ECT. 

Send all samples and appropriate APHIS 2060 forms to the AMS-NSL laboratory. 

Ship all samples and supporting documentation in accordance with protocols and 

procedures.

d. Notification of the laboratory prior to shipping any priority, spill, or unusual (i.e. 

other than water, insect, or vegetation) samples.
Environmental Monitoring Supplies Checklist (ver. Feb. 2012)

Environmental Monitoring Supplies Checklist

- use the blank areas to indicate the number of items to take to the field or 

how many of that item are being ordered

General Supplies Dye Cards

Monitoring plan/SOP’s Obtain from 

ECT

Oil-sensitive dye cards (one card 

per package)

Field log notebook Water-sensitive dye cards (two 

paired cards per package)

2060 monitoring forms 5' bamboo poles/stakes Obtain locally

Indelible marker Obtain locally Paper/alligator clips Obtain locally

12” x 12" resealable plastic bags Tacks/nails Obtain locally

Styrofoam coolers for mailing Tweezers Obtain locally

Shipping label (AMS-National 

Science Laboratory in Gastonia, NC) Nitrile gloves (box of S,M,L,XL)

Indicate size

Packing/strapping tape Vegetation/Fish/Insect Samples

Ice chest and wet or blue ice Obtain locally Pruning shears/scissors Obtain locally

Soil Samples Tweezers/forceps Obtain locally

Hand trowel Obtain locally Packing/strapping tape

10” x 14” foil envelopes 10” x 14” foil envelopes

Neat (Pure) Chemical & Formulations Water Samples

Amber glass bottle (2 ounce size) Cubitainer (gallon size)

Disposable pipette and bulb Cubitainer (liter size)

Small mailing tubes Sodium sulfate (small vials)

Protective eyewear pH paper (0-14 range)

Nitrile gloves (box of S,M,L,XL) Indicate size Acid or base (in a squeeze bottle) Obtain locally

Program: _________________________________ Requested by: ______________________________ 

Date: _____________________________________ Phone: ____________________________________ 

Address: ____________________________________________________________________________________

____________________________________________________________________________________________

To order supplies, indicate the quantity of each item needed. Fax or email a copy of this form to APHIS-CPHST in 

Mississippi at 228-822-3137 or robert.d.smith@aphis.usda.gov. If fax machines are not working, leave a message 

with the monitoring supplies manager at 228-323-5326. It may be difficult to fill orders for large quantities of 

materials.

This is not an exhaustive supply list...items that are not listed here may be available through CPHST. Not all 

supplies listed above are required for all pest control programs.